Your privacy is important to us. This policy explains how First HR Connect collects, uses, and protects your personal information.

1. Introduction & Scope

First HR Connect Inc. ("we," "our," or "the Company") is committed to protecting the privacy and security of personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information of our employees, job applicants, website visitors, and clients in compliance with applicable privacy laws and regulations.

This policy applies to all personal information received by First HR Connect in any format including electronic, paper, or verbal. All employees, representatives, and agents of First HR Connect are required to follow this policy and its procedures for protecting personal information.

• Policy Application: This policy governs our handling of employee data, applicant information, client data, and website visitor information.
• Consent: By providing personal information to us, you consent to the collection, use, and disclosure practices described in this Privacy Policy.
• Policy Updates: We reserve the right to modify this policy at any time. The "Last Updated" date at the top indicates when the latest revisions were made.

2. Information We Collect

First HR Connect collects various types of personal information necessary for our business operations, human resource functions, and service delivery:

2.1 Personal Information from Employees and Job Applicants

• Identifiers: Name, alias, postal address, email address, telephone number, or other similar identifiers.
• Professional Information: Employment history, education background, resume/CV content, interview notes, performance reviews, disciplinary records, compensation and benefits information, and training records.
• Protected Characteristics: Race, skin color, national origin, religion, sex/gender, gender identity, sexual orientation, marital status, medical condition, disability, military status, and age where required or permitted by law.
• Financial Information: Banking details for payroll, tax information, salary, bonus, and expense records.
• Technical Data: Information required to provide access to company IT systems, including IP addresses, login information, and software/hardware inventories.

2.2 Information from Website Visitors and Clients

• Contact Information: Name, email address, phone number, company name, and job title when you inquire about our services.
• Technical Information: Cookies, usage data, IP address, browser type, operating system, and pages visited on our website.
• Communications: Content of emails, phone conversations, or other communications with our team.

3. How We Use Personal Information

We limit our use of personal data to specific, necessary business purposes with appropriate legal bases:

3.1 Human Resources Purposes

• Workforce Administration: Employee hiring, onboarding, payroll processing, benefits administration, performance management, and training development.
• Legal Compliance: Complying with employment laws, tax regulations, safety requirements, and other governmental reporting obligations.
• Workplace Operations: Managing company IT systems, ensuring physical security, conducting internal investigations, and maintaining emergency contact information.

3.2 Business and Service Purposes

• Service Delivery: Providing HR consulting, staffing, recruitment, and other requested services to our clients.
• Client Communication: Responding to inquiries, sending requested information, and providing customer support.
• Business Improvement: Analyzing website usage, improving our services, developing new offerings, and conducting market research.
• Marketing: Sending information about services, events, and content that may be of interest (with opt-out options).

3.3 Legal Bases for Processing

We process personal information based on one or more of the following legal grounds:

• Contractual Necessity: Performance of an employment contract or service agreement.
• Legal Obligation: Compliance with applicable laws and regulations.
• Legitimate Interests: Operating our business, ensuring security, and preventing fraud.
• Consent: Where required by law, we obtain explicit consent for specific processing activities.

4. How We Share Personal Information

First HR Connect does not sell personal information. We may share information in these limited circumstances:

4.1 Within Our Organization

Personal information may be shared internally on a need-to-know basis with authorized personnel across our organization for legitimate business purposes.

4.2 With Third-Party Service Providers

We engage trusted third parties to perform business functions, such as:

• IT and Infrastructure: Cloud storage providers, software vendors, and IT support.
• Business Operations: Payroll processors, benefits administrators, background check vendors, and professional advisors.
• Marketing Tools: Email marketing platforms, analytics providers, and customer relationship management systems.

All service providers are contractually obligated to protect personal information and use it only for the services they provide.

4.3 For Legal and Business Transfers

We may disclose personal information:

• Legal Compliance: When required by law, court order, or governmental regulation.
• Business Protection: To protect our rights, property, or safety, or that of our employees, clients, or others.
• Corporate Transactions: In connection with a merger, acquisition, or sale of company assets.

Circumstance	Types of Information Shared	Recipients
Payroll Processing	Name, banking details, salary information	Payroll service providers
Benefits Administration	Medical information, dependents' information	Benefits administrators
Legal Compliance	Information required by specific regulations	Government agencies
Client Services	Applicant resumes, employment information	Client organizations (with consent)

5. Data Security and Retention

5.1 Security Measures

We implement appropriate technical and organizational measures to protect personal information against unauthorized access, disclosure, alteration, or destruction. Our security practices include:

• Physical Security: Secure offices, locked filing cabinets, and access-controlled facilities.
• Technical Safeguards: Encryption, firewalls, secure network infrastructure, and access controls.
• Administrative Controls: Security awareness training, confidentiality agreements, and need-to-know access restrictions.

5.2 Data Retention

We retain personal information only as long as necessary for legitimate business purposes and legal compliance. Our retention practices include:

• Employee Records: Maintained during employment and for required post-employment periods as mandated by law.
• Applicant Information: Retained for consideration for future positions unless instructed otherwise.
• Business Records: Kept for duration of client relationships and beyond as required by contractual or legal obligations.

6. Individual Rights and Choices

Depending on your jurisdiction and relationship with First HR Connect, you may have certain rights regarding your personal information:

6.1 Access and Correction Rights

• Access: You may request access to the personal information we hold about you.
• Correction: You may request corrections to inaccurate or incomplete personal information.
• Portability: Where technically feasible, you may request transfer of your data to another controller.

6.2 Additional Privacy Rights

• Withdrawal of Consent: Where processing is based on consent, you may withdraw consent at any time.
• Deletion: You may request deletion of personal information when no longer necessary for original purposes.
• Objection: You may object to certain processing activities, particularly for direct marketing.
• Restriction: You may request limitation of processing in certain circumstances.

6.3 Exercising Your Rights

To exercise any of these rights, please contact us using the information in Section 9. We will respond to legitimate requests within one month as required by applicable law. We may need to verify your identity before processing certain requests.

7. International Data Transfers

For global operations, First HR Connect may transfer personal information across borders. When transferring data internationally, we implement appropriate safeguards as required by applicable laws, which may include:

• Adequacy Decisions: Transferring to countries with adequate data protection laws.
• Standard Contractual Clauses: Using approved contractual clauses for data protection.
• Certification Programs: Relying on valid privacy frameworks like Data Privacy Framework for EU-US transfers.

8. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to enhance user experience and analyze site usage:

• Essential Cookies: Required for basic website functionality and security.
• Functional Cookies: Remember user preferences and settings.
• Analytical Cookies: Help us understand how visitors interact with our website.

You can manage cookie preferences through your browser settings. However, disabling essential cookies may impact website functionality.

9. Contact Information

For questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

• Email: privacy@firsthrconnect.com
• Phone: +1 (972) 638-0103‬‬
• Address: First HR Connect Inc., 315 Madison Avenue, New York, NY 10017

If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.

10. Policy Updates

This Privacy Policy may be updated periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes through appropriate channels and update the "Last Updated" date at the top of this policy.